[cabfpub] Ballot 170 - Amend Section 5.1 of Baseline Requirements

Michael Markevich mmarkevich at opera.com
Thu Jun 16 09:17:32 UTC 2016

Opera abstains.

In our opinion, the nature and the wording of the proposed requirements
will not allow to apply them efficiently. For example, such terms as
"sufficient" or "robust" are quite vague and do not provide the *sufficient*
basis for implementation or further audit. Using any of the
industry-adopted standards for data-center construction and maintenance
could be a better option.


On 2 June 2016 at 22:04, Ben Wilson <ben.wilson at digicert.com> wrote:

> *Ballot 170 - Amend Section 5.1 of Baseline Requirements*
> The Policy Review Working Group has reviewed Section 5.1 of the Baseline
> Requirements and, as a result, suggests that certain changes be made.
> Therefore, the following motion has been proposed by Ben Wilson of DigiCert
> and endorsed by Robin Alden of Comodo and Li-Chun CHEN of Chunghwa Telecom:
> In Section 5.1.1 Site location and construction add:
> The location and construction of the facilities housing the CA and RA
> equipment SHALL be consistent with facilities used to house high-value,
> sensitive information. The site location and construction, when combined
> with other physical security protection mechanisms such as guards, high
> security locks, and intrusion sensors, SHALL provide robust protection
> against unauthorized access to the CA equipment and records.
> In Section 5.1.2 Physical access add:
> CAs SHALL maintain controls to provide reasonable assurance that: physical
> access to CA facilities and equipment is limited to authorized individuals,
> protected through restricted security perimeters, and is operated under
> multiple person (at least dual custody) control; CA facilities and
> equipment are protected from environmental hazards; loss, damage or
> compromise of assets and interruption to business activities are prevented;
> and compromise of information and information processing facilities is
> prevented.
> In Section 5.1.3 Power and air conditioning add:
> The CA SHALL have backup power capability sufficient to lock out input,
> finish any pending actions, and record the state of the equipment
> automatically before lack of power or air conditioning causes a shutdown.
> The backup power capabilities SHALL support the availability requirements
> of Section 4.10.2.
> In Section 5.1.4 Water exposures add:
> CA equipment SHALL be installed such that it is not in danger of exposure
> to water (e.g., on tables or elevated floors). Potential water damage from
> fire prevention and protection measures (e.g., sprinkler systems) SHOULD be
> minimized.
> In Section 5.1.5 Fire prevention and protection add:
> The CA SHALL comply with local commercial building codes for fire
> prevention and protection.
> In Section 5.1.6 Media storage add:
> Media SHALL be stored so as to protect it from accidental damage (water,
> fire, electromagnetic) and unauthorized physical access. Media not required
> for daily operation or not required by policy to remain with the CA or RA
> that contains security audit, archive, or backup information SHALL be
> stored securely in a location separate from the CA or RA equipment.
> Media containing private key material SHALL be handled, packaged, and
> stored in a manner compliant with the requirements for the sensitivity
> level of the information it protects or to which it provides access.
> Storage protection of CA and RA private key material SHALL be consistent
> with stipulations in Section 5.1.2.
> In Section 5.1.7 Waste disposal add:
> Sensitive media and documentation that are no longer needed for operations
> SHALL be destroyed in a secure manner. For example, sensitive paper
> documentation shall be shredded, burned, or otherwise rendered
> unrecoverable.
> In Section 5.1.8 Off-site backup add:
> The purpose of an off-site backup is to recover from system failure
> resulting from damage to the equipment or similar causes. For components of
> the Certificate System operated in an online fashion, any backup necessary
> to recover from system failure SHALL be made at least once per week or so
> that no changes made prior to the last week might be lost. Root CA Systems
> and other components operated in an offline fashion SHALL be backed up
> prior to taking them offline. Only the latest backup needs to be retained.
> The backup SHALL be stored at a separate site with physical and procedural
> controls sufficient to protect the confidentiality, integrity, and
> availability of the information backed up.
> The review period for this ballot shall commence at 2200 UTC on 2 June
> 2016, and will close at 2200 UTC on 9 June 2016. Unless the motion is
> withdrawn during the review period, the voting period will start
> immediately thereafter and will close at 2200 UTC on 16 June 2016. Votes
> must be cast by posting an on-list reply to this thread.
> A vote in favor of the motion must indicate a clear 'yes' in the response.
> A vote against must indicate a clear 'no' in the response. A vote to
> abstain must indicate a clear 'abstain' in the response. Unclear responses
> will not be counted. The latest vote received from any representative of a
> voting member before the close of the voting period will be counted. Voting
> members are listed here: https://cabforum.org/members/
> In order for the motion to be adopted, two thirds or more of the votes
> cast by members in the CA category and greater than 50% of the votes cast
> by members in the browser category must be in favor. Quorum is currently
> ten (10) members– at least ten members must participate in the ballot,
> either by voting in favor, voting against, or abstaining.
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Michael Markevich
Head of Security and Privacy
Opera Software
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